Telehealth Policy & Resources

Medicare Telehealth Policy

Medicare telehealth policy shifted dramatically for the entire healthcare industry in response to COVID-19. Telehealth policy unique to RHCs and more broadly within the fee-for-service community evolved rapidly in a matter of months, expanding avenues for patients to see providers, but also creating unique hurdles that NARHC is working to fix.

Through December 31, 2024 (at least!) RHCs can provide telehealth services and be reimbursed but only through the special payment rule established in the CARES Act. The special payment rule pays RHCs/FQHCs through a system based on the weighted average of physician fee schedule codes billable via telehealth.

Operationally, this means that RHCs bill one single code, G2025, which pays a single rate, $95.29, for any and all of the over 220+ services that are billable via telehealth. Codes billable as audio-only are noted within the CMS spreadsheet.

Further complicating the current policy landscape is the fact that in the 2022 Medicare Physician Fee Schedule, CMS changed the definition of an RHC/FQHC mental health encounter to allow mental health services provided via telehealth to be reimbursed through normal payment mechanisms. In other words, for mental health telehealth services, RHCs/FQHCs already have payment parity.

Telehealth Resources

Below are some resources to help RHCs navigate the shifting telehealth landscape. With any questions, please email Sarah Hohman at Sarah.Hohman@narhc.org.

  • All RHCs billing for telehealth should review the MLN Matters document: New and Expanded Flexibilities for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) During the COVID-19 Public Health Emergency (PHE).
  • Beginning January 2022 and not connected to the PHE, RHCs can bill and be reimbursed for mental health services provided via telehealth. More information can be found here.
  • In December 2020 CMS announced significant telehealth coinsurance changes.
  • Table 1 below breaks down the types of telehealth services RHC can bill for and how to bill for, including what was billable during the COVID-19 Public Health Emergency and the services’ temporary or permanent status. The majority of telehealth waivers will require further legislative action if they are to remain permanent.
  • Table 2 below highlights the various Medicare telehealth waivers and their current status as of early 2024.

NARHC Telehealth Advocacy

NARHC is advocating for:

  • Permanent coverage of medical telehealth encounters
  • A revision of the RHC/FQHC payment policy to ensure that RHCs do not experience a disparity in reimbursement when seeing patients via telehealth

Congress must take action by December 31, 2024 to avoid Medicare medical telehealth policy from reverting to limited, pre-COVID-19 pandemic rules.

Bills introduced in the 118th Congress that achieve telehealth reimbursement parity for RHCs include:

  • The HEALTH Act, H.R.5611
  • CONNECT for Health Act of 2023, S.2016/H.R.4189
  • Save America’s Rural Hospitals Act, H.R.833
  • Telehealth Modernization Act H.R.7623/S.3967

NOTE: The Protecting Rural Telehealth Access Act, S.1636, also addresses telehealth reimbursement for RHCs. However, the changes included in this legislation are not preferable to the bills listed above. While it extends RHC (and FQHC) telehealth coverage, in effect it would create a new special payment rule and maintain the billing difficulties that come along with it. Additionally, NARHC does not support perpetuating the current temporary rule which disadvantages RHCs who wish to invest in telehealth (H.R.5541).

NARHC is also open to appropriate guardrails to ensure that the integrity of the telehealth benefit is protected in our safety net provider settings.

Please consider taking a moment to contact your members of Congress using the Voter Voice tool (on the right side of this page) to ensure your RHC’s voice is heard on telehealth policy!

Table 1

Name of Telehealth Service

Brief Description

How to Bill

Reimbursement Rate

  Relevant 
 Dates

Virtual Check-In or Virtual Care Communications

Remote evaluation - G2010
Brief communication with patient (5 min) - G2012

G0071
Bill on UB-04
No modifier necessary
Rev Code

052X

2022:
$23.88

2023:
$23.72

2024:
$12.93

Permanent
coverage 

Digital e-Visits

Online evaluation and management

99421-99423

 

G0071
Bill on UB-04
No modifier
Rev Code 052X

2022:
$23.88

2023:
$23.72

Only billable
during the
COVID-19 PHE
(ended
May 11, 2023).

Telehealth Visits

One to one substitutes or additions to in-person services/visits

List of allowable services maintained by CMS
(including services allowed via audio-only)

G2025
Bill on UB-04 Modifier 95 optional
Modifier CS (for services where cost sharing is waived

Rev Code 052X

Costs and encounters carved out of cost report

2022:
$97.24

2023:
$98.27

2024:
$95.37

 Currently
set to expire
December 31, 2024
Mental Health
Telehealth Visits

One to one substitutes or additions to in-person mental health services/visits

CPT codes that can be billed with 0900 revenue code

Rev Code 0900

Use proper mental health CPT code

Modifier CG always

Modifier 95 if audio-video

Modifier FQ or 93 if audio-only
Count costs and encounters on cost report

All-Inclusive
Rates

Permanent
coverage
beginning
January 1, 2022

*Occasional in-person
visit requirement
begin on
January 1, 2025
 
Chronic Care Management/
Principal Care Management/Remote Physiologic Monitoring/Remote Therapeutic Monitoring

Psychiatric Care Management
 G0323, 99487, 99490, 99491, 99424, 99426, G3002, G3003, 99453, 99454, 99457, 99458, 99091, 98975, 98976. 98977, 98980, 98981, G0019, G0022, G0023, and G0024 = G0511
99492, 99493 = G0512

G0511- Care Management

G0512- Psychiatric Care Management

G0511 2022-
$79.25

G0511 2023-
$77.94

G0512 2022-
$151.23

G0512 2023-
$146.73

G0511 2024:
$71.68

G0512 2024:
$144.07

 In 2024, CMS greatly
expanded care 
management policy
for RHCs. RHCs can
bill for Remote
Physiological
Monitoring and 
several others (as
G0511) and are 
eligible to bill for 
multiple G0511 codes
per patient per month.
Details here.
Transitional Care Management Supporting the additional work provided to patients following discharge from an acute care setting to prevent errors and readmissions. 99495, 99496 on an RHC claim, either alone or with other payable services  If it is the only medical service provided on that day with an RHC or FQHC practitioner it is paid as a stand-alone billable visit. If it is furnished on the same day as another visit, only one visit is paid. Covered since January 1, 2013 

 

Table 2

 Medicare Policy Area  Current Policy and Duration of Flexibility/Waiver
 Originating Site/Geographic Requirements  Patients can receive telehealth services in their home or anywhere else through December 31, 2024.
 Distant Site Requirements  RHC providers can serve as telehealth distant site providers through December 31, 2024. RHC providers can offer telehealth services from any location, including their home, during this period.
 Billing/Cost Reporting Requirements  Please see table above. G2025 policy for medical telehealth visits remains in effect  through December 31, 2024.
 Modality  The Office of Civil Rights allowed for “non-public facing” remote communication products to be used for telehealth services, “exercising discretion” on stringent HIPAA compliant platform requirements. This ended on May 11, 2023 

 

Other Telehealth Information of Interest

  • The Drug Enforcement Agency extended the flexibilities for prescribing controlled substances via telehealth through December 31, 2024.
  • HHS provided resources on educating patients on privacy and security risks when using telehealth.